In both the EU and the US, the global financial crisis and the euro crisis triggered important changes to bank resolution frameworks. Bank resolution in both jurisdictions shares the objectives of making financial institutions resolvable without threatening financial stability, while protecting taxpayer money. But the different environments and different crisis features and experiences have led to different structures on the two sides of the Atlantic. While the US evolved towards remedying a blind spot within an already existing integrated system, Europe changed its approach from coordination to centralization.
1. Post-crisis resolution regimes: scope and triggers
1.1 The US: a blind spot
1.2 EU: from coordination to centralization
2. Resolution strategies and tools
3. Funding, backstops and the use of public funds
3.1 The US ordinary liquidation fund
3.2 The EU’s Single Resolution Fund